Archive

COMMUNITY BANK GUIDE – FINTECH DUE DILIGENCE

On August 27, 2021, the Federal Reserve, FDIC, and OCC released a 20-page guide intended to help community banks assess risks when considering relationships with financial technology (fintech) companies. Community banks are entering into business arrangements with fintech companies to offer enhanced products and services to their customers, increase efficiency, and reduce internal costs. The guide is intended to serve as a resource for community banks when performing due diligence on prospective relationships with fintech […]

OCC UPDATES CRA, FAIR HOUSING AND ECOA POSTERS AND NOTICES

On August 5, 2021, the Office of the Comptroller of the Currency (OCC) published OCC Bulletin 2021-35 which informs national banks, federal savings associations, and federal branches and agencies of foreign banking organizations of the appropriate names and addresses for notices required by the Community Reinvestment Act and Equal Credit Opportunity Act, and for posters under the Fair Housing Act. Community Reinvestment Act—Public Notice by Banks 12 CFR 25.30 requires banks to provide the public […]

JOINT AGENCY EFFORT TO IMPROVE CRA

On July 20, 2021, the Federal Reserve Board (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) jointly announced the agencies are committed to working together to strengthen and modernize regulations implementing the Community Reinvestment Act (CRA). The OCC separately announced it will propose rescinding the CRA final rule issued in May 2020 and is committed to working with the Board and the FDIC to put forward […]

PROPOSED INTERAGENCY GUIDANCE ON THIRD-PARTY RELATIONSHIPS

On July 15, 2021, the Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), and the Office of the Comptroller of the Currency (OCC) issued an interagency proposed rule on managing risks associated with third-party relationships. The proposed guidance would: Offer a framework based on sound risk management principles for banking organizations to consider in developing risk management practices for all stages in the life cycle of third-party relationships […]

OCC RECONSIDERING THE 2020 CRA RULE

On May 18, 2021, the Office of the Comptroller of the Currency (OCC) published OCC Bulletin 2021-2, which states that the OCC has determined that it will reconsider the final CRA Rule published on June 5, 2020. While this reconsideration is ongoing, the OCC: Will not object to the suspension of the development of systems for, or other implementation of, provisions with a compliance date of January 1, 2023, or January 1, 2024, under the […]